FCA US LLC Testimony on: 

Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium-and 

Heavy- Duty Engines and Vehicles- Phase 2 

August 6, 2015 

Palmer House Hilton Hotel- Chicago, IL 

Good Morning, my name is Gary Oshnock; I am the Manager responsible 

for NAFTA Fuel Economy and Greenhouse Gas Regulatory Compliance at 

FCA US LLC. 

The FCA US product lineup features some of the world's most recognizable 

trucks, and engines in this segment. Those trucks include the Class 2 thru 5 

variants of our popular Ram pick-ups and our Class 2b Pro Master® 

commercial vans. Gasoline engines include the award winning 3.6L 

Pentastar V6 and the 5.7L and 6.4L Hemi® V8 engines. Diesel engines 

include the class leading 6.7L Cummins® Turbo Diesel16 and our 3.0L 

EcoDiesel14. 

Thank you for the opportunity to speak here today and show support for 

the U.S. EPA (United States Environmental Protection Agency) and NHTSA 

(National Highway Traffic Safety Administration) efforts to develop the 

second set of greenhouse gas and fuel consumption rules for the medium 

and heavy-duty vehicle segment. 

We fully support and commend this 2019 through 2027 model year Phase 2 

initiative, as we did the collaboration that produced the national Phase I 

rule. FCA US remains committed to the proliferation of clean technology 

and reducing vehicle operating costs, while ensuring our products continue 

to deliver the performance and functionality our customers demand and 

deserve. 

As EPA and NHTSA noted in the light-duty program, a single National 

Program "hold[s] out the promise of delivering environmental and energy 
benefits, cost savings, and administrative efficiencies that might not be 

available under a less coordinated approach"- FCA US unequivocally 

agrees. 

While we are still analyzing the proposed rule, I have a few initial 

comments and suggestions: 

• We support EPA and N HTSA's attribute-based standards that recognize 

the utility and functionality of these work trucks. Payload and towing 

capacity are important to the owners of these work trucks. These "work 

factor based" standards acknowledge the inherently higher greenhouse 

gas emissions and fuel consumption of higher capability vehicles. 

• While the light-duty vehicle fleet has been regulated under NHTSA's 

CAFE program for roughly forty years, we are still very early in the 

heavy-duty program. We formally have one full model year of industry 

data "under our belt." 

• Given this limited baseline of real data, it is concerning that there have 

been calls for even greater stringency beyond the aggressive standards 

proposed by EPA and NHTSA for Phase 2. Comments regarding 

stringency need to address the many contributing factors- both explicit 

and implicit. These factors include, but are not limited to: 

1. These work trucks have a wide range of "duty-cycles" so the values of 

the different technologies vary from a customer perspective. 

2. The challenges of year-over-year stringency increases with effectively 

only two products available to "average" in the 2b/3 segment. 

3. The concurrent stringency increases in Tier 3/LEV Ill criteria emission 

requirements and how to manage the increased thermal loads on 

aftertreatment systems. 

4. The impact of changing test fuels and the test procedure adjustments 

that will be needed. 
5. Additional technologies will be needed, given that some Phase 2 

technologies are already in the fleet today. (For example, FCA US has /! 

cylinder deactivation and cooled EGR in today's vehicles, making 

these technologies unavailable for improvements in Phase 2). 

• FCA US strongly believes that a single national fuel consumption and 

greenhouse gas program will place more clean and efficient vehicles on 

the road quickly and at lower costs. Our resources are best utilized when 

applied to one, single, national standard versus differing state-level fuel 

consumption and greenhouse gas requirements. 

• As far as A/C system improvements, we believe there is value in 

recognizing the greenhouse gas and fuel consumption contributions 

from reducing the energy demand of the A/C systems. We also believe 

there is an additional opportunity to further harmonize with the lightduty program and recognize the added greenhouse gas emission 

benefit, beyond leak reduction, that switching to a lower global warming 

potential refrigerant ca n provide. 

• We support the flexibility mechanisms included in the ru le: averaging, 

banking and trading and recognition of the benefits of technologies not 

captured on laboratory drive cycles. We wil l work with the agencies to 

make these processes more efficient in the second phase of t his 

program. 

In closing, FCA US will continue reviewing the proposed rule and submit 

these and other comments as part of the formal rulemaking process. We 

wi ll work with EPA and NHTSA and other stakeholders to ensure that an 

implementable rule is finalized on schedule. 

Thank You.